#oshaviolations

To perform service or maintenance safely and effectively under Lockout Tagout, employees must be provided with protective equipment, hardware and appliances for isolating, securing, or blocking of machines & equipment from their energy sources. Under paragraph (c)(5) of the OSHA Standard, it is the employers’ responsibility to provide necessary devices. Protective material and hardware that may be needed include locks, tags, cable ties, chains, breakers and valve lockouts, wedges, blocks, blinds, pins, fasteners and other hardware.

When launching a lockout tagout program, a survey of the workplace is needed, not only to identify the machines, equipment and processes that are covered by the program, but also to become familiar with the configuration of the equipment. When ordering the necessary hardware, the employer must also ensure that the hardware meets specific requirements for design & construction.

Under paragraph (c)(5)(ii) it states that the Lockout & Tagout devices should be singularly identified. Which means- the best suitable device should be placed on the isolating point and should not be used for any other purpose apart from Lockout Tagout on machines & equipment.

Section A-D of paragraph (c)(5)(ii) specifies certain requirements of lockout Tagout devices, i.e. The device must be durable, Standardized, Substantial and Identifiable.

In paragraph 1910.147(c)(5)(iii), OSHA requires that the major message printed on the tag “warn against hazardous condition of the equipment is re-energized. Five examples of acceptable warnings are provided, including Do Not Start. Do Not Open. Do Not Close. Do Not Energize. Do Not Operate. In all cases, employees must know and understand the meaning of the Tag.

Energy Control Procedures or Machine Specific Procedures need to be developed, documented & utilized always for full employee protection. If the total employee protection is obtained without ECP, then the need for developing ECP can be exempted. But all the essential elements required for complete safety of the employees have to be fulfilled.

The exemption is mostly for the simple equipment, when the Lockout device is under the exclusive control of the authorized employee, there is no potential for inadvertent release of stored or residual energy, and a single lockout device can achieve a locked-out condition. But in industries, even the complicated machines do not have the ECP. Many times when there are replicas of the same equipment, then the generic or common ECPs are used which leads to a lot of confusion & adequate energy control is not achieved, resulting in serious accidents.

So, ECPs are required for the isolation of hazardous energies & absence of ECP is the most common violation as per OSHA Standard 29 CFR 1910.147.

Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-29-cfr-1910-147-explained/